The Upper Tax Tribunal has decided in the Tower Radio appeal that employee bonuses paid as shares, not cash, in specially formed subsidiaries were not caught by income tax or national insurance. The case involved a promoted scheme using the restricted securities regime in part 7 of ITEPA 2003. The Tribunal, after considering the Ramsay principle, found the result unattractive but still within the ambit of ITEPA. Taxpayers’ appeal was allowed. The case is reported as Tower Radio & Total Property v HMRC  UKUT 60 (TCC) Feb/15.
Tax Barrister, Accountant